Foreign Currency Purchase Certificate (DAB) for Turkish Citizenship by Property Investment

Foreign Currency Purchase Certificate (DAB) for Turkish Citizenship by Property Investment

17.10.2026

DAB Turkish Citizenship: Legal Purpose and Regulatory Framework

Under Turkish law, acquiring qualifying real estate is one of the investment routes for exceptional acquisition of Turkish citizenship. The legal basis is Article 12(1)(b) of Law No. 5901 on Turkish Citizenship and Article 20 of its implementing Regulation. The current property investment threshold is USD 400,000 or its equivalent in foreign currency or Turkish lira. The property must also be subject to a three-year restriction against sale in the land registry.

The Foreign Currency Purchase Certificate, known as the Döviz Alım Belgesi or DAB, is a banking document connected with the foreign currency conversion required for a foreign person's real estate acquisition. It is not itself a citizenship certificate, title deed or Certificate of Conformity.

The DAB procedure became applicable to foreign real persons acquiring real estate through purchase from 24 January 2022. TKGM states that the foreign currency must first be sold through a bank to the Central Bank of the Republic of Türkiye, after which the bank issues the DAB for submission to the land registry office.

The DAB requirement should be distinguished from the citizenship investment requirement. The DAB establishes the relevant currency conversion within the property transaction, while the title deed, payment records and Certificate of Conformity address other parts of the investment and citizenship process.

For citizenship-related property acquisitions, TKGM also requires evidence of the payment made from the buyer to the seller. Its official announcement expressly states that, in addition to the DAB, a bank transfer receipt concerning the buyer-to-seller payment must be submitted. Consulting an English-speaking lawyer in Turkey helps foreign buyers coordinate these initial banking procedures and legal requirements accurately before transaction funds are remitted.

This distinction is important because the DAB does not independently establish that the statutory investment requirement has been fulfilled. The property, payment, title deed restriction and other applicable conditions must all satisfy the relevant legal and administrative requirements.

The current USD 400,000 threshold should also be distinguished from the previous USD 250,000 threshold. The threshold was increased to USD 400,000 in 2022, and transactions involving earlier payments may be subject to transitional rules depending on their dates and structure.

Accordingly, the applicable rules should be assessed by reference to the transaction chronology where payments, contracts or applications span different regulatory periods.

Obtaining and Using the DAB for a Property Investment

The DAB is issued by the bank through which the relevant foreign currency transaction is completed. The buyer does not obtain it directly from the land registry or the citizenship authorities.

Under the applicable procedure, the foreign currency is sold through a bank to the Central Bank of the Republic of Türkiye. The bank then issues the DAB, which is submitted to the relevant land registry office. TKGM expressly confirms this procedure in its guidance for foreign real estate acquisitions.

The DAB should therefore be regarded as part of the banking stage of the property acquisition. It should not be confused with the sale agreement, title deed or separate bank receipt evidencing payment to the seller.

The DAB must contain information that allows the currency conversion to be connected with the relevant purchaser and property transaction. TKGM's implementation guidance addresses the identification and property information required for this purpose.

This connection becomes particularly important where the acquisition is intended to support a citizenship application. The purchaser's identity, the property information and the financial records should be consistent throughout the transaction.

The Turkish lira amount corresponding to the foreign currency sold is also relevant to the land registry transaction. TKGM states that the Turkish lira amount shown in the DAB is taken into account as the amount relevant to the official deed for the purposes specified in its guidance.

For citizenship-related acquisitions, however, the DAB is not the only payment evidence required. TKGM specifically requires the bank receipt showing the transfer from the buyer to the seller.

The payment trail should therefore be considered as a whole. The currency conversion, the corresponding Turkish lira amount, the payment to the seller and the title deed records should be capable of being reconciled.

Where a transaction involves several payments, the dates of those payments become particularly important. TKGM's current implementation guidance contains specific rules for payments made before and after the DAB procedure entered into force.

For example, payments made before 24 January 2022 may be evidenced through the relevant bank receipts rather than a DAB, subject to the applicable transitional rules. Later payments may require the corresponding DAB documentation.

The same issue can arise in instalment transactions. TKGM's guidance explains how pre-DAB payments and subsequent payments supported by DABs are treated when determining the relevant property value.

The DAB should therefore be planned as part of the property transaction rather than treated as an administrative document to obtain after the purchase has otherwise been completed.

DAB Compliance Issues and Common Legal Risks

The principal compliance issue is consistency between the DAB, the property transaction and the payment records. A DAB may have been issued correctly while another document still contains information that requires clarification.

The amount represented by the DAB should be connected with the property transaction. TKGM guidance addresses circumstances where amounts outside the property sale price appear in the currency conversion documentation and requires such amounts to be appropriately identified.

This distinction matters when determining whether the statutory citizenship investment threshold has been reached. Taxes, fees, commissions and other transaction expenses should not simply be added to the property price on the assumption that they automatically constitute part of the qualifying investment.

The buyer-to-seller payment evidence is also a separate compliance requirement. TKGM expressly states that the bank transfer receipt showing the relevant payment from the buyer to the seller is required in citizenship-related property acquisitions.

A discrepancy between the DAB and the payment receipt should therefore be investigated before the citizenship file is submitted. The difference may arise from the payment date, exchange-rate treatment, instalment structure or another feature of the transaction.

The property must independently satisfy the requirements applicable to the citizenship route. The current NVİ guidance confirms the USD 400,000 minimum and the requirement for a three-year restriction against sale to be recorded in the title deed.

Meeting the financial threshold does not therefore resolve other eligibility issues. The property and transaction must also comply with the applicable rules concerning the parties, acquisition structure and land registry records.

TKGM's citizenship implementation guidance contains additional restrictions concerning certain properties previously transferred by Turkish citizens, foreign persons and persons who acquired citizenship under the investment route. These rules can be relevant particularly in transactions involving second-hand properties.

The transaction chronology should also be reviewed where payments were made under different regulatory regimes. TKGM's guidance specifically addresses payments made before 24 January 2022 and certain instalment and sale-promise transactions. Relying on professional residency and citizenship support services in Turkey ensures that transitional rules, currency conversion logs, and compliance records are thoroughly audited prior to filing the application.

This means that the date of the payment, currency conversion, property acquisition and relevant application can affect which documentary requirements apply.

For a foreign buyer, the legal risk is therefore not limited to obtaining a DAB. The entire documentary chain should be reviewed before the transaction is relied upon for citizenship purposes.

Citizenship Application and DAB Documentation

The property investment process involves both an investment eligibility assessment and a subsequent citizenship application. The current NVİ guidance states that an applicant must satisfy one of the investment conditions in Article 20 of the implementing Regulation and obtain the relevant Certificate of Conformity before proceeding with the citizenship application.

For a property investment, the Certificate of Conformity is issued through the competent land registry authorities under the framework administered by TKGM. NVİ identifies TKGM as the relevant authority for the property acquisition investment route.

The DAB forms part of the documentation supporting the property investment. It should be retained together with the relevant bank transfer receipts, title deed documentation and other records required for the eligibility assessment.

The DAB does not itself grant Turkish citizenship and does not constitute the Certificate of Conformity. Its function is to document the relevant foreign currency conversion within the property acquisition process.

The three-year restriction is a separate requirement. For the property investment route, the current official guidance requires the property to be registered with a three-year restriction against sale.

After the investment requirement has been established and the Certificate of Conformity obtained, the applicant proceeds through the prescribed citizenship process. NVİ currently identifies the subsequent stages as including the relevant short-term residence permit process and the citizenship application.

The applicant's documentary file should therefore show a clear connection between the foreign currency conversion, the property payment, the property registration and the investment eligibility assessment.

Where multiple payments, purchasers or properties are involved, the records should be reviewed together. Particular attention should be given to the identity of the purchaser, the property reference, the payment dates and the amounts appearing on the DAB and bank receipts.

The same applies where payments were made before and after the DAB requirement entered into force. TKGM's guidance provides specific rules for these circumstances, and the transaction should be assessed according to the applicable provisions rather than by applying the current procedure retrospectively.

The DAB should consequently be treated as part of the transaction planning process. Obtaining the document is only one step; ensuring that it corresponds with the wider property and payment documentation is equally important.

FAQ

What is a DAB and why is it required for Turkish citizenship by property investment?

A DAB is a bank-issued Foreign Currency Purchase Certificate documenting the relevant foreign currency conversion. For foreign real estate acquisitions, the DAB procedure has applied since 24 January 2022 under the applicable banking and land registry rules.

Does the DAB need to correspond to the property purchase payment?

The DAB should correspond with the underlying property transaction. For citizenship-related acquisitions, TKGM also requires the bank receipt showing the transfer from the buyer to the seller.

What happens if the DAB or payment documentation is incomplete?

The property investment must be properly evidenced before the Certificate of Conformity can be issued. Inconsistent or incomplete DAB, payment, or title deed records may prevent the citizenship process.

Summary

The DAB is a banking document forming an important part of the evidential framework for qualifying Turkish property investments. It records the relevant foreign currency conversion and supports the land registry process, while the buyer-to-seller bank receipt provides separate evidence of the property payment. The current citizenship property route requires an investment of at least USD 400,000 and a three-year sale restriction, subject to the applicable legal and transitional rules. The DAB should therefore be reviewed together with the payment and title deed documentation before the citizenship application proceeds.

For legal assistance with your DAB, property investment or Turkish citizenship application, contact Gokalp Legal.

This article provides general information and does not constitute legal advice.